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Requirements guide · Reviewed 30 September 2026

What does a battery passport need to contain?

A guide to the scope, responsibilities and information behind the EU requirement. Use the official sources linked below to check the obligations for your battery and role.

18 Feb 2027Passport requirement for batteries in scope

Which batteries are in scope?

From 18 Feb 2027, Article 77 requires a passport for LMT batteries, electric-vehicle batteries and industrial batteries with capacity greater than 2 kWh placed on the market or put into service. The 2 kWh threshold applies to industrial batteries, not to the EV or LMT categories. This is not a blanket instruction to retrofit every battery already operating in a fleet.

By category: EV traction batteries · LMT batteries · industrial and storage

Source: Regulation (EU) 2023/1542, Article 77(1)

Who maintains the record?

The responsible economic operator must keep passport information accurate, complete and current. Another operator may be authorised to act on its behalf. Information is attached to both the battery model and the individual battery; access differs by reader and purpose.

Source: Article 77 and Annex XIII

It takes more than telemetry.

The Commission describes information covering identification, technical characteristics, manufacturer and operator details, performance, durability, repair, reuse, recycling and sustainability. Applicability depends on the battery category and requirement.

A QR code connects the battery to its passport. Detailed information remains with the responsible operator in a decentralised system; a registry entry does not replace that record. Consult the Commission’s category-specific data-point document when mapping your fields.

Source: European Commission — battery passport requirements and category data

Great Britain, Northern Ireland and EU supply are different cases.

UK government guidance says the EU Batteries Regulation applies directly in Northern Ireland. Great Britain continues under its existing battery rules; the guidance also describes plans to consult on a UK-wide aligned regime. A planned consultation is not an enacted obligation.

For a UK business supplying batteries into the EU, assess the EU market requirements and your role in that supply chain. “UK-based” is not, by itself, an answer to whether a passport is needed.

Great Britain, Northern Ireland and EU supply, in full

Source: UK government — EU Batteries Regulations in Northern Ireland

A practical preparation checklist

The following is our suggested workflow, not a complete legal compliance checklist.

  1. Establish scope. Confirm battery category, capacity, destination market and the operator responsible.
  2. Map information to its owner. Separate supplier documents, model specifications and individual battery observations. Record missing evidence.
  3. Check access and continuity. Plan who can read which information and how the record will be maintained over time.
  4. Validate the implementation. Review identifiers, QR access, registry arrangements and applicable technical requirements against the official guidance.
  5. Test with real source data. Confirm which measurements arrive, how estimates are identified and what happens when data is missing.

Where Adaptr fits

Adaptr’s pilot supports operational history and passport record management. It does not offer automatic EU registry submission or certify regulatory compliance. Review the capabilities before deciding what else your implementation needs.